Long-Term Care Hospital (LTCH) Continuity Assessment Record and Evaluation Data Set (LCDS) Quarterly Q&As September 2021 Consolidated September ...
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Long-Term Care Hospital (LTCH) Continuity Assessment
Record and Evaluation Data Set (LCDS)
Quarterly Q&As
September 2021
Consolidated September 2020 to September 2021Introduction
The Centers for Medicare & Medicaid Services (CMS) is publishing the Long-Term Care Hospital
(LTCH) Continuity Assessment Record and Evaluation Data Set (LCDS) Quarterly Q&As so that
all LTCH providers have the clarifications to existing guidance. Through inquiries to the LTCH
Post-Acute Care (PAC) Quality Reporting Program (QRP) Help Desk, CMS identifies the
opportunity to clarify or refine guidance.
New Q&As Added in September 2021
1. GG0130, GG0170
Question 8
2. M0300
Question 4
3. N2005
Question 1
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page i of iiConsolidated Table of Contents
Introduction ............................................................................................................................................ i
New Q&As Added in September 2021 ................................................................................................ i
Admission Items: General Questions .................................................................................................. 1
Section GG: Functional Abilities and Goals ....................................................................................... 2
GG0100, GG0110 ............................................................................................................................. 2
GG0110 ............................................................................................................................................. 2
GG0130, GG0170 ............................................................................................................................. 3
GG0130A .......................................................................................................................................... 6
GG0130B........................................................................................................................................... 7
GG0130C........................................................................................................................................... 7
GG0170 ............................................................................................................................................. 8
GG0170C........................................................................................................................................... 9
GG0170E ........................................................................................................................................... 9
GG0170F ......................................................................................................................................... 10
GG0170I, GG0170J, GG0170K..................................................................................................... 12
GG0170I .......................................................................................................................................... 13
GG0170Q ........................................................................................................................................ 14
GG0170R, GG0170S ...................................................................................................................... 15
GG0170S ......................................................................................................................................... 16
Section H: Bladder and Bowel ........................................................................................................... 17
H0350 .............................................................................................................................................. 17
H0400 .............................................................................................................................................. 18
Section K: Swallowing/Nutritional Status ........................................................................................ 19
K0200 .............................................................................................................................................. 19
Section M: Skin Conditions ............................................................................................................... 20
M0210, M0300................................................................................................................................ 20
M0300 .............................................................................................................................................. 20
Section N: Medications ...................................................................................................................... 22
N2005 .............................................................................................................................................. 22
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page ii of iiAdmission Items: General Questions
Question 1: If a patient is admitted to a Long-Term Care Hospital (LTCH) on Monday but
has to be transferred back to the acute care hospital the next day (Tuesday) and then returns
to the LTCH on Thursday, we know that this is considered a program interruption. Can we
use assessment information from Tuesday morning’s functional assessments (the day the
patient returned to the acute care hospital) to code the admission items?
Answer 1: If the patient has a program interruption, the assessment data gathered on the discharge
date (the day the patient is admitted to Acute Care from the LTCH) may be used to code the
admission items.
At times CMS provides new or refined instruction that supersedes previously published guidance.
In such cases, use the most recent guidance.
Added: September 2020
Question 2: In the latest Q&A release, there was a question that spoke to a decline with a
patient within the assessment window with instructions to not update the assessment with
such. The example given was related to dysphagia following an ER stay. I am questioning
now if we can identify other “updates” within the 3-day admission assessment time period.
Answer 2: Each LCDS item should be considered individually, and coded based on the guidance
provided for that item.
Unless otherwise specified in item guidance, information collected by the assessing clinician
during the time period for the specified assessment type may be used to inform LCDS coding.
Note that item guidance does specify special rules for coding pressure ulcer/injury and GG items
at admission. To support consistency of data collection related to pressure ulcers and GG function
data across all post-acute care (PAC) providers, cross-setting guidance directs coding for pressure
ulcers/injuries to be based on the “first skin assessment” and GG self-care and mobility items
should be based on a functional assessment that occurs at or soon after the patient’s admission,
and reflect the patient’s baseline ability to complete the activity, prior to the benefit of services
provided by your facility staff.
Added: June 2021
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 1 of 22Section GG: Functional Abilities and Goals
GG0100, GG0110
Question 1: We have questions regarding prior level of functioning and prior device use. A
patient is admitted to our facility for rehab, has a medical issue, and is discharged to an acute
care hospital for a week. When the patient returns to our facility, would the prior level of
functioning reported in GG0100B - Prior Functioning: Indoor Mobility reflect the patient’s
ambulation status prior to the original admission (which is the reason we are still treating
the patient) or is the prior level of functioning based on what the patient was doing during
the hospital stay? Would this also apply to GG0110 - Prior Device Use?
Answer 1: The intent of GG0100B - Prior Functioning: Indoor Mobility is to report the patient’s
need for assistance with walking from room to room, with or without a device such as a cane,
crutch, or walker, prior to the current illness, exacerbation, or injury. The intent of GG0110 - Prior
Device Use is to indicate which devices and aids were used by the patient prior to the current
illness, exacerbation, or injury. The assessing clinician must consider each patient’s unique
circumstances and use clinical judgment to determine how prior functioning and prior device use
apply for each individual patient.
In responding to GG0100 - Prior Functioning: Everyday Activities, the activities should be
reported based on the patient’s usual ability prior to the current illness, exacerbation, or injury.
This is the patient’s functional ability prior to the onset of the current illness, exacerbation of a
chronic condition, or injury, whichever is most recent, that initiated this episode of care. Clinicians
should use clinical judgment within these parameters in determining the time frame that is
considered “prior to the current illness, exacerbation, or injury.”
The same approach should be used in determining Prior Device Use for GG0110.
Added: September 2020
GG0110
Question 1: Should a transport chair be considered a “wheelchair” for GG0110 - Prior
Device Use?
Answer 1: The intent of GG0110 - Prior Device Use is to indicate which devices and aids were
used by the patient prior to the current illness, exacerbation, or injury. The assessing clinician must
consider each patient’s unique circumstances and use clinical judgment to determine how prior
device use applies for each individual patient.
CMS does not provide an exhaustive list of assistive devices that may be used when coding prior
device use.
Added: December 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 2 of 22GG0130, GG0170
Question 1: For section GG what is the definition of “therapeutic intervention”?
Answer 1: At Admission, the self-care or mobility performance code is to reflect the patient’s
baseline ability to complete the activity, prior to the benefit of services provided by your facility
staff. “Prior to the benefit of services” means prior to provision of any care by your facility staff
that would result in more independent coding.
Please note that the term “prior to the benefit of services” replaces the term “therapeutic
intervention” for the GG activities.
At times CMS provides new or refined instruction that supersedes previously published guidance.
In such cases, use the most recent guidance.
Added: September 2020
Question 2: Establishing a goal is required for at least one self-care or mobility activity in
section GG. Can the GG goals be changed once established during the first 3 days if the
patient’s status changes?
Answer 2: The GG Self-care and Mobility Discharge Goals are used in the calculation of the
Process Measure - Percentage of Patients with an Admission and Discharge Function Assessment
and a Care Plan that Addresses Function. The measure reports, in part, that discharge goals were
established, and does not take into consideration whether or not the goals were met. Once a goal
is established, there is no need to update it if circumstances change or additional information
becomes available either within or after the 3-day assessment time period.
Added: September 2020
Question 3: The LTCH CARE Data Set (LCDS) manual for section GG clarifies that a Code
03-Partial/moderate assistance indicates the helper is required to provide less than half the
effort and a Code 02-Substantial/maximal assistance indicates the helper is required to
provide more than half the effort. If a helper is required to provide exactly half the effort,
how would the item be coded?
Answer 3: In the situation described, the helper and patient each are providing exactly half of the
effort to complete a GG activity. If the patient performs half of the effort, code the item 03-
Partial/moderate assistance.
Added: September 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 3 of 22Question 4: On day 2, during an evaluation, the physical therapist feels the patient is unable
to complete an activity such as sit to stand without providing therapy services; for example:
skilled instruction on safe body mechanics for transfers or proper technique to maintain
weight bearing restrictions. Is it appropriate to code 88 as the admission assessment of
baseline functional status prior to benefiting from therapy services? PT initiates treatment
by providing a walker, instructing in its use, and offering cues for proper technique. The
patient performed sit to stand transfers with moderate assistance the rest of the day 2 and
day 3.
Answer 4: At Admission, the self-care or mobility performance code is to reflect the patient’s
baseline ability to complete the activity, prior to the benefit of services provided by your facility
staff.
For the admission assessment, the patient may be assessed based on the first use of an assistive
device or equipment that has not been previously used. The clinician would provide assistance, as
needed, in order for the patient to complete the activity safely, and code based on the type and
amount of assistance required, prior to the benefit of services provided by your facility/staff.
Introducing a new device should not automatically be considered as “providing a service.”
Whether a device used during the clinical assessment is new to the patient or not, use clinical
judgment to code based on the type and amount of assistance that is required for the patient to
complete the activity prior to the benefit of services provided by your facility/staff.
Communicating the activity request (e.g., “Can you stand up from the toilet?”) would not be
considered verbal cueing. If additional prompts are required in order for the patient to safely
complete the activity (“Push down on the grab bar,” etc.), the assessing clinician may need to use
clinical judgment to determine the most appropriate code, utilizing the Coding Section GG
Activities Decision Tree.
In your scenario, if even with assistance the patient was unable to perform the sit to stand activity
prior to the benefit of services and the performance code cannot be determined based on
patient/caregiver report, collaboration with other agency staff, or assessment of similar activities,
use the appropriate “activity not attempted” code.
Added: September 2020
Question 5: We understand that if a patient initially refuses to attempt an activity during the
assessment period, but later agrees to perform the activity, the code that represents the
patient’s actual performance supersedes the refusal code (07). What if on day 1 or day 2 a
safety or medical issue prevents the patient from attempting an activity, but on day 3, after
benefiting from therapeutic intervention, the patient can now perform the activity? Which
code should be reported on the LCDS: Code 88 - Not attempted due to medical conditions or
safety concerns, or one of the performance codes, 01-06?
Answer 5: At Admission, the self-care or mobility performance code is to reflect the patient’s
baseline ability to complete the activity, prior to the benefit of services provided by your facility
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 4 of 22staff. “Prior to the benefit of services” means prior to provision of any care by your facility staff
that would result in more independent coding.
Use of an “activity not attempted” code should occur only after determining that the activity is not
completed prior to the benefit of services, and the performance code cannot be determined based
on patient/caregiver report, collaboration with other facility staff, or assessment of similar
activities.
If this is the case in your scenario code 88 even if the patient’s status changes and the patient is
able to complete the activity on a later day during the assessment period.
Added: September 2020
Question 6: How would you code the following scenario for GG activities: Two people are
present when a patient is performing an activity; one person is assisting the patient and the
second person is standing by for safety/assist as needed but when the activity is completed
the second person was not needed. Would you code the activity as Code 01 - Dependent due
to having the second person present just in case, or code based on the type and amount of
assistance provided by the one person only?
Answer 6: For the GG self-care and mobility activities Code 01 - Dependent is when a helper is
required to do all the effort and the patient does none of the effort to complete the activity, or the
assistance of two or more helpers is required for the patient to complete the activity.
If the role of the second helper is to provide standby assistance, then the presence of two helpers
meets the definition of Code 01 - Dependent. This would be true even if the second helper was
there for supervision/standby assist and did not end up needing to provide hands-on assistance.
Added: March 2021
Question 7: How should the following situation be coded for the GG0130 - Self-Care and
GG0170 - Mobility items? On discharge a patient was nonadherent with spinal precautions.
She was able to demonstrate completing functional tasks independently with good balance
and strength, and was cognitively intact. By her report, she was choosing not to routinely
adhere to spinal precautions in her day-to-day activities, although she was aware of the
precautions and risks. Should the GG activities be coded based on her ability, which is
independent, or based on the fact that she knowingly breaks her precautions?
Answer 7: The GG activities focus on the patient’s ability to complete the activities as
independently as possible as long as they are safe; willingness and nonadherence are not the focus
of the coding.
If, in your scenario, you have assessed the patient being able to independently complete the GG
activities safely, code 06 - Independent.
Added: June 2021
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 5 of 22[NEW] Question 8: For GG0130 - Self-Care and GG0170 - Mobility, it is our facility’s policy
that a patient always have a staff member present during walking or toileting activities. Is it
possible for the GG activity to be assessed and coded 06 - Independent, for situations where
a staff member is required to be present per facility policy, but is not required to assist or
supervise the patient in any way?
Answer 8: When assessing self-care and mobility activities, allow the patient to complete each
activity as independently as possible, as long as he/she is safe.
If a helper is present (only due to facility policy) code the activity based on the type and amount
of assistance the patient requires to complete the activity as independently as possible, as long as
they are safe. If no assistance/supervision/set-up is required, then code 06 - Independent.
Added: September 2021
GG0130A
Question 1: How would the following scenario for GG0130A - Eating be coded: A patient
was admitted and on day 1 required only setup assistance for eating. On day 2 the patient
was transferred to an acute care hospital and returned on day 3 with an overall decline in
status and was made NPO due to dysphagia. Would we code 05 - Setup or clean-up assistance
based on initial ability or 88 - Not attempted due to medical conditions or safety concerns
because this is the new baseline following the decline?
Answer 1: The intent of GG0130A - Eating is to assess the patient’s ability to use suitable utensils
to bring food and/or liquid to the mouth and swallow food and/or liquid once the meal is placed
before the patient.
At admission, the performance code is to reflect the patient’s baseline ability to complete the
activity, prior to the benefit of services provided by your facility staff.
In the scenario provided, use Code 05 - Setup or clean-up assistance for GG0130A - Eating if this
represents the patient’s baseline status.
Only use an “activity not attempted” code if the patient was not able to complete the activity prior
to the benefit of services and the performance code cannot be determined based on
patient/caregiver report, collaboration with other facility staff, or assessment of similar activities.
Added: December 2020
Question 2: How would you code GG0130A - Eating for a patient who has been on tube
feeding for years but is able to drink water independently?
Answer 2: The intent of GG0130A - Eating is to assess the patient’s ability to use suitable utensils
to bring food and/or liquid to the mouth and swallow food and/or liquid once the meal is placed
before the patient. For a patient taking only fluids by mouth, the item may be coded based on
ability to bring liquid to mouth, once the drink is placed in front of the patient.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 6 of 22When coding activities in Section GG, clinicians should code based on the patient’s baseline ability
during the 3-day assessment period. Allow the patient to perform the activity as independently as
possible, as long as the patient is safe, regardless of the food consistency and regardless of how
the patient performed the activity prior to the current illness, exacerbation, or injury.
In the scenario, if the patient is independently taking liquids by mouth, code 06 - Independent.
Added: March 2021
GG0130B
Question 1: A helper gathers and sets out the patient’s oral hygiene items. The patient is able
to brush their teeth with steadying assist from a helper while standing at the sink. What is
the code for oral hygiene?
Answer 1: The intent of GG0130B - Oral hygiene is to determine the patient’s ability to use
suitable items to clean teeth. Dentures (if applicable): The ability to insert and remove dentures
into and from the mouth, and manage denture soaking and rinsing with use of equipment.
When coding activities in Section GG, clinicians should code based on the type and amount of
assistance required to complete the activity, allowing the patient to perform the activity as
independently as possible, as long as they are safe.
In your scenario, if the patient standing at the sink requiring steadying assistance to brush their
teeth represents the patient performing the activity as independently as possible, then code 04-
Supervision or touching assistance for GG0130B - Oral hygiene.
Added: September 2020
GG0130C
Question 1: A patient used a bedpan for both bowel and bladder and was able to lift and
lower her hospital gown (no brief or underwear were stated to be present), and the patient
was not able to perform any of her own perineal hygiene for bowel or bladder. How is
Toileting hygiene coded?
Answer 1: The intent of GG0130C - Toileting hygiene is to assess the patient’s ability to maintain
perineal hygiene and adjust clothes before and after voiding or having a bowel movement.
In your scenario, code GG0130C - Toileting hygiene based on the type and amount of assistance
required to complete the ENTIRE activity, including toileting hygiene and adjusting any clothing
relevant to the individual patient (in this case lifting and lowering the hospital gown). If, in the
assessing clinician’s clinical judgment, the patient required a helper to provide less than half the
effort, then code 03-Partial/moderate assistance; or if the patient required the helper to provide
more than half the effort code 02-Substantial/maximal assistance.
Added: September 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 7 of 22Question 2: If a patient is admitted to an LTCH with a Foley catheter and does not have a
bowel movement during the 3-day assessment period how should GG0130C - Toileting
hygiene be coded? Would it be Code 88 - Not attempted due to medical conditions or safety
concerns or can the nurse code the activity based on how much assistance the patient requires
to manage the Foley bag?
Answer 2: The intent of GG0130C - Toileting hygiene is to assess the patient’s ability to maintain
perineal hygiene and adjust clothes (including undergarments and incontinence briefs) before and
after voiding or having a bowel movement.
The toileting hygiene activity can be assessed and coded regardless of the patient’s need to void
or have a bowel movement.
If a patient has a Foley catheter, toileting hygiene includes perineal hygiene to the indwelling
catheter site. It does not include management of the equipment.
If the patient has an indwelling urinary catheter and has bowel movements, code the toileting
hygiene item based on the type and amount of assistance needed by the patient before and after
moving his or her bowels. This may necessarily include the need to perform perineal hygiene to
the indwelling urinary catheter site after the bowel movement.
If a patient manages an ostomy, include wiping the opening of the ostomy or colostomy bag but
not managing equipment for GG0130C - Toileting hygiene.
Added: June 2021
Question 3: How should GG0130C - Toileting hygiene be coded if a patient requires different
types and amount of assistance after voiding versus after having a bowel movement?
Answer 3: The intent of GG0130C - Toileting hygiene is to assess the patient’s ability to maintain
perineal hygiene and adjust clothes (including undergarments and incontinence briefs) before and
after voiding or having a bowel movement.
When the patient requires different levels of assistance to perform toileting hygiene after voiding
vs. after a bowel movement, code based on the type and amount of assistance required to complete
the ENTIRE activity. This is true even in scenarios where GG0130C - Toileting hygiene is not
completed entirely during one clinical observation.
Added: June 2021
GG0170
Question 1: If a patient is dependent for all GG bed mobility activities would it be acceptable
to code the patient as dependent for all other GG mobility activities even if those activities
were not specifically assessed?
Answer 1: At Admission, the mobility performance code is to reflect the patient’s baseline ability
to complete the activity, and is based on observation of activities, to the extent possible. Clinicians
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 8 of 22may assess the patient’s performance based on direct observation (preferred) as well as reports
from the patient and/or family, assessment of similar activities, collaboration with other facility
staff, and other relevant strategies to complete all GG items.
Each LCDS item should be considered individually and coded based on the guidance provided for
that item.
It is important to determine whether the appropriate code for each GG activity is a performance
code (including 01 - Dependent) vs. an “activity not attempted” code.
It is also important to note that a helper cannot complete the walking activities for a patient. The
walking activities cannot be considered completed without some level of patient participation that
allows patient ambulation to occur the entire stated distance. For instance, if even with assistance
a patient was not able to participate in walking a distance of 10 feet, an “activity not attempted”
code (rather than 01 - Dependent) would be selected.
Added: December 2020
GG0170C
Question 1: How do we code lying to sitting on side of bed for a bilateral amputee not wearing
their prosthetics, since the definition states “with feet on floor”?
Answer 1: If the patient with a unilateral (or bilateral) lower extremity amputation does not have
or is not wearing a prosthesis (or prostheses), use clinical judgment to determine if the patient
completes the activity (Lying to sitting on side of bed without back support). Code the activity
based upon the type and amount of assistance the patient requires to safely complete the activity.
Added: September 2020
GG0170E
Question 1: We understand that verbal cueing during a task should fall under the score of
04-Supervision or touching assistance. Our question is can a verbal cue provided prior to the
task be considered set up as long as no further cues were provided during the actual task?
A specific example we just encountered was during the “chair/bed to chair transfer” activity.
The therapist cued the patient prior to the activity where to place their hand for stability (in
a novel environment), and then the patient completed all of the activity safely and without
further cues or assistance. Is this Code 05-Setup or Code 04-Supervision?
Answer 1: When assessing self-care and mobility activities, allow the patient to complete each
activity as independently as possible, as long as he/she is safe. At admission, the self-care or
mobility performance code is to reflect the patient’s baseline ability to complete the activity prior
to benefit of services provided by your facility/staff. This may be achieved by having the patient
attempt the activity prior to providing any instruction that could result in a more independent code,
and coding based on the type and amount of assistance required.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 9 of 22Communicating the activity request (e.g., “Can you stand up from the toilet?”) would not be
considered verbal cueing. If additional prompts are required in order for the patient to safely
complete the activity (“Push down on the grab bar,” etc.), the assessing clinician may need to use
clinical judgment to determine the most appropriate code, utilizing the Coding Section GG
Activities Decision Tree.
In the scenarios described, assuming the verbal cues were only provided prior to the benefit of
services and were required, and no other assistance was needed in order for the patient to complete
the activity safely, then the verbal cues would be considered 05-Setup.
Added: September 2020
Question 2: We have a patient who at discharge requires max assistance to perform a
transfer, so is coded as 02 - Substantial/maximal assistance for GG0170E - Chair/bed-to-
chair transfer. This maximal assist transfer will not be safe for the patient and elderly family
to attempt once at home, so two family members will be using a Hoyer lift to transfer the
patient from bed to chair. At discharge, would the correct code for GG0170E be 02 -
Substantial/maximal assistance, based on the patient’s performance in the facility; or would
the correct code be 01 - Dependent, because that is what the patient’s “usual” status will be
at home?
Answer 2: The intent of GG0170E - Chair/bed-to-chair transfer is to assess the patient’s ability to
transfer to and from a bed to a chair (or wheelchair).
When assessing self-care and mobility activities, allow the patient to complete each activity as
independently as possible, as long as he/she is safe.
If the patient performed the activity during the discharge assessment period, code based on that
assessment. Use the GG 6-point scale codes to identify the patient’s usual performance on the
discharge assessment.
If in your scenario, at discharge, when allowed to complete the activity as independently as
possible, the patient was able to safely complete the transfer activity with max assist, then code
02 - Substantial/maximal assistance.
Added: December 2020
GG0170F
Question 1: If a patient gets up off the side of the bed, walks to the bathroom, and then sits
down on the toilet, is the effort necessary to lift up off the bed considered for coding GG0170F
- Toilet transfer?
Answer 1: The intent of GG0170F - Toilet transfer is to assess the patient’s ability to get on and
off a toilet (with or without a raised toilet seat) or commode once the patient is at the toilet or
commode.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 10 of 22In the scenario described, the effort necessary to lift up off the bed does not count toward the toilet
transfer in GG0170F - Toilet transfer.
Added: September 2020
Question 2: A patient completes a toilet transfer requiring only supervision. As he was
ambulating with contact guard assistance back to his bed he lost his balance and required
assistance to steady himself. Would the contact guard assist and assistance to steady himself
be considered in determining the performance code for GG0170F - Toilet transfer?
Answer 2: The intent of GG0170F - Toilet transfer is to assess the patient’s ability to get on and
off a toilet (with or without a raised toilet seat) or commode once the patient is at the toilet or
commode.
In the scenario described, the assistance provided while ambulating to or from the toilet should not
be considered when coding the GG0170F - Toilet transfer activity.
Added: December 2020
Question 3: In the recent September Quarterly Q&A publication, it indicates that
“assessment of similar activities” is acceptable for coding the LCDS. Please provide
clarification on if the following scenarios would be acceptable simulations for the GG0170F
- Toilet transfer activity in situations where a patient does not need to use the toilet during
an assessment:
1. An Occupational Therapist (OT) takes the patient to the toilet and simulates a
toileting experience, with patient pulling down pants and transferring onto the toilet
and then back to the chair.
2. Using the functional performance of the patient’s Chair/bed-to-chair transfer
performance code to code toilet transfer.
3. Using the functional performance of the patient’s ability to transfer on and off a
bedside commode in the therapy gym to code toilet transfer.
Answer 3: The intent of GG0170F - Toilet transfer is to assess the patient’s ability to get on and
off a toilet or commode. Do not consider or include GG0130C - Toileting hygiene item tasks
(managing clothing, undergarments, or perineal hygiene) when coding the toilet transfer item. The
toilet transfer activity can be assessed and coded regardless of the patient’s need to void or have a
bowel movement in conjunction with the toilet transfer assessment.
Use clinical judgment to determine if each situation described adequately represents the patient’s
ability to transfer on and off the toilet or commode. If the clinician determines that this observation
is adequate, code based on the type and amount of assistance the patient requires to complete the
activity.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 11 of 22In each scenario, if the patient was not able to transfer on/off the toilet or commode and the
performance code cannot be determined based on patient/caregiver report, collaboration with other
facility staff, or assessment of similar activities, use the appropriate “activity not attempted” code.
Added: December 2020
GG0170I, GG0170J, GG0170K
Question 1: Many of our patients with a stroke ambulate with PT along a railing mounted
in the hall. We understand that walking/transferring in the parallel bars would not be used
to code the GG activities. Could coding be based on the patient walking in the hallway if
using a railing as a support?
Answer 1: The intent of the walking items (GG0170I, GG0170J, GG0170K) is to assess the
patient’s ability to ambulate once in a standing position.
As noted in your question, you would not code self-care and mobility activities with use of a device
that is restricted to patient use during therapy sessions (e.g., parallel bars, exoskeleton, or overhead
track and harness systems). Note that while a patient may use a hallway railing during therapy
sessions, its use would not be restricted to therapy sessions only and therefore does not meet the
definition described above.
CMS does not provide an exhaustive list of assistive devices that may be used when coding self-
care and mobility performance. Other than the exceptions listed above, clinical assessments may
include any device or equipment (including a hallway railing) that the patient can use to allow
them to safely complete the activity as independently as possible.
Added September 2020
Question 2: If a patient requires a therapist to provide steadying assistance/contact guard
assist and manage an oxygen tank while the patient is ambulating how would the walking
activities be coded?
Answer 2: The intent of the GG0170 walking items is to assess the patient’s ability once standing
to safely walk the stated distances and circumstances in each item.
If the helper is required to manage the oxygen tank and/or oxygen tubing and/or provide steadying
assistance/contact guard, to allow the patient to complete an activity safely, then code 04 -
Supervision or touching assistance.
Added: March 2021
Question 3: At discharge, if it is not recommended that a patient ambulate when they return
home because it is not functional for them or if a discharge goal was not selected for an
activity, should the GG walking activities still be assessed and coded with a performance
code or should an “activity not attempted” code be used?
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 12 of 22Answer 3: Assessment of the GG self-care and mobility items is based on the patient’s ability to
complete the activity with or without assistance and/or a device. This is true regardless of whether
or not the activity is being/will be routinely performed (e.g., walking may be assessed for a patient
who did/does/will use a wheelchair as their primary mode of mobility).
At discharge, code based on the patient’s ability to complete each activity regardless of whether a
goal was established for that activity at admission.
If the patient is able to complete a walking activity with the assistance of one or two people, code
based on the type and amount of assistance required even if walking is not being recommended or
used as a functional mode of mobility.
If based on the guidance stated above, you are unable to determine the patient’s discharge ability
in conjunction with all current discharge assessment findings or the patient is not able to complete
a walking activity safely even with the assistance of two people, code using the appropriate
“activity not attempted” code.
Added: June 2021
GG0170I
Question 1: Can you give some clarification regarding scoring a performance with the help
of a second person (if this second person is helping push an oxygen tank, IV pole, or
wheelchair following the patient) because the first helper is physically assisting the patient
during the walking activity? Both helpers are needed to complete the activity safely. The
IRF-PAI manual says “if two or more helpers are required to assist the patient to complete
the activity, code as 01, Dependent.”
Answer 1: The intent of the GG0170 walking items is to assess the patient’s ability once standing
to safely walk the stated distances and circumstances in each item.
You are correct that if a patient requires the assistance of two helpers to complete an activity (one
to provide support to the patient and a second to manage the necessary equipment to allow the safe
walk), Code 01 - Dependent is the appropriate code.
If a single helper only manages the oxygen tank or the IV pole and otherwise the patient needs no
assistance to safely complete the walking activity, code the walking activity as 04 – Supervision
or touching assistance. This is because the helper is required to be present during the activity for
the patient to complete the activity safely.
Added: September 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 13 of 22Question 2: How would you code a situation where the patient walks part of the distance, say
4 feet, and then the helper carries them the remaining distance to get to the 10 feet needed
for GG0170I - Walk 10 feet? Would this be a Code 02-Substantial/maximal assistance
because the helper is carrying the patient the majority of the distance? We understand that
with the wheelchair activities a helper can complete the distance needed by pushing the
patient in the wheelchair. Is this also true for the walking items?
Answer 2: The intent of the walking item GG0170I - Walk 10 feet is to assess the type and amount
of assistance a patient requires to ambulate 10 feet once in a standing position.
Since a helper cannot complete a walking activity for a patient, the walking activities cannot be
considered completed without some level of patient participation that allows patient ambulation to
occur for the entire stated distance.
In your scenario, where the patient participates in walking 4 feet and then requires the helper to
carry them for further distances, the activity walking 10 feet (GG0170I) is not considered
completed. If the stated distance of 10 feet was not walked by the patient, with or without some
level of assistance, GG0170I would be coded with one of the “activity not attempted” codes, for
example 88-Not attempted due to the medical condition or safety concerns.
Each LCDS item should be considered individually and coded based on the guidance provided for
that item.
Added: September 2020
GG0170Q
Question 1: We have a question regarding the appropriate scoring for an LTCH patient who
does not use a wheelchair during the admission assessment, but then begins to use a
wheelchair later during the LTCH stay. Our system software will not allow us to upload
goals after the 3-day admission assessment has ended. When a patient does begin using a
wheelchair later in the stay, would it be appropriate to go back to the initial wheelchair
assessment on the LCDS and change GG0170Q to “YES” and add the corresponding goals
even though they were established after the admission assessment has ended?
Answer 1: The intent of GG0170Q - Does the patient use a wheelchair and/or scooter? is to
document whether a patient uses a wheelchair or scooter at the time of the assessment. Only code
0-No if, at the time of the assessment, the patient does not use a wheelchair or scooter under any
condition.
If, at the time of admission, GG0170Q is answered “No” correctly, and following the admission
assessment period the patient begins to utilize a wheelchair, there is no need to update the
admission performance and/or discharge goals for GG0170 activities on the admission LCDS. The
gateway wheelchair item (GG0170Q1 and GG0170Q3) might not be coded the same on the
admission and discharge assessments.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 14 of 22If, at the time of admission, GG0170Q was answered incorrectly then corrections to the admission
LCDS should be made following Federal, State, and facility policy guidelines.
Added: September 2020
Question 2: If a patient utilizes a wheelchair for mobility and is able to wheel 50 feet with 2
turns but is unable to wheel 150 feet (code 07, 09, 10, 88), how should we code items
GG0170S/SS1? There is not a skip pattern if one of the “activity not attempted” codes are
used for GG0170S, and the guidance on the LCDS states for GG0170SS1 to “Indicate the
type of wheelchair or scooter used.” Selecting one or the other does not feel logical but using
a dash [-] impacts compliance with the LTCH QRP.
Answer 2: You are correct that there is no skip pattern for GG0170S/SS1 unless GG0170Q1 is
answered “no.” However, for the wheelchair items, a helper can assist the patient to complete the
activity or make turns if required. Therefore, if the patient is unable to wheel the entire distance
with or without assistance the activity can still be completed, and a performance code can be
determined based on the type and amount of assistance required to complete the entire activity.
If, in your scenario, the patient was unable to complete the 150 feet themselves, GG0170S - Wheel
150 feet could still be coded with a performance code based on the type and amount of assistance
required to complete the entire activity. Then GG0170SS1 could indicate the type of wheelchair
used.
Added: June 2021
GG0170R, GG0170S
Question 1: Regarding Section GG Wheelchair Items, does the activity of wheeling 50 feet
with 2 turns need to be done independent of the activity of wheeling 150 feet?
Also the manual states the coding is based on an assessment completed before therapeutic
intervention. Patients who had not used a wheelchair previously may not be able to complete
both wheelchair activities. Would an “activity not attempted” code be used?
Answer 1: The intent of GG0170R - Wheel 50 feet with two turns is to assess the patient’s ability,
once seated in wheelchair/scooter, to wheel at least 50 feet and make two turns.
The intent of GG0170S - Wheel 150 feet is to assess the patient’s ability, once seated in a
wheelchair/scooter, to wheel at least 150 feet in a corridor or similar space.
Use clinical judgment to determine how the actual patient assessment of wheelchair mobility is
conducted. If a clinician chooses to combine the assessment of multiple wheelchair activities, use
clinical judgment to determine the type and amount of assistance needed for each individual
activity.
At Admission, the performance code is to reflect the patient’s baseline ability to complete the
activity, prior to the benefit of services provided by your facility staff.
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 15 of 22The patient may be assessed based on the first use of an assistive device or equipment that has not
been previously used. The clinician would provide assistance, as needed, in order for the patient
to complete the activity safely. The item would then be coded based on the type and amount of
assistance required, prior to the benefit of services provided by your facility staff.
“Prior to the benefit of services” means prior to provision of any care by your facility staff that
would result in more independent coding.
Introducing a new device should not automatically be considered as “providing a service”.
Whether a device used during the clinical assessment is new to the patient or not, use clinical
judgment to code based on the type and amount of assistance that is required for the patient to
complete the activity prior to the benefit of services provided by your facility.
Added: December 2020
GG0170S
Question 1: A patient was able to propel his wheelchair for 100 feet with moderate assistance.
He was unable to go farther and the therapist pushed the wheelchair the rest of the way to
the gym, which was a total of 150 feet. What score would you give this patient for GG0170S
- Wheel 150 feet?
Answer 1: The intent of GG0170S - Wheel 150 feet is to assess the patient’s ability, once seated
in a wheelchair/scooter, to wheel at least 150 feet. If the patient is unable to complete the entire
distance required for this activity, the assessing clinician can assist the patient to complete the
activity, and code this item based on the type and amount of assistance required to complete the
entire activity.
In your example, the patient completed wheeling 100 feet of the 150 feet with moderate assistance
and required the helper to complete the remaining distance. Use clinical judgment to determine if
the patient required the helper to provide less than half the effort (then code 03-Partial/moderate
assistance) or if the patient required the helper to provide more than half the effort (then code 02-
Substantial/maximal assistance).
Added: September 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 16 of 22Section H: Bladder and Bowel
H0350
Question 1: Please clarify the use of the code 4 - Always incontinent for H0350 - Bladder
Continence. The coding instructions state that this code is used if during the 3-day assessment
period the patient had no continent voids. What if during the 3-day assessment period the
patient has no continent episodes because the patient was catheterized during some portion
of the 3-day assessment period?
Answer 1: The intent of H0350 - Bladder Continence is to gather information on bladder
continence. Code 4 - Always Incontinent is applicable when the patient had no continent voids and
did not require the use of any type of catheter at any time during the 3-day assessment period.
Added: December 2020
Question 2: How would the following scenarios for H0350 - Bladder Continence be coded?
Scenario 1
Day 1: One intermittent catheterization, no other bladder episodes
Day 2: Foley was placed, no other bladder episodes
Day 3: Foley remained in place the entire day
Would this scenario be coded as 9 - Not applicable because the patient had a Foley in place
for 2 of the 3 days or as 0 - Always Continent because there were no episodes of incontinence
in between intermittent catheterization; even though there were no continent episodes
either?
Scenario 2
Day 1: Intermittent catheterizations, no bladder episodes in between catheterizations
Day 2: Intermittent catheterizations, no bladder episodes in between catheterizations
Day 3: Intermittent catheterizations, no bladder episodes in between catheterizations
Answer 2: The intent of H0350 - Bladder Continence is to gather information on bladder
continence. Incontinence refers to the involuntary loss of urine, when there is a loss of control of
the evacuation of urine from the bladder, regardless of whether clothing or linens are soiled.
In both scenarios, if intermittent catheterization is used to empty the bladder and there are no
episodes of incontinence between catheterizations, H0350 - Bladder Continence is coded 0 -
Always continent (no documented incontinence). Code 09 - Not applicable would not apply for
either scenario as the patient did not have a catheter in place for the entire 3-day assessment period.
Added: December 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 17 of 22H0400
Question 1: If a patient only has one bowel movement during the admission assessment
period, and that bowel movement is incontinent, how would H0400 be coded? With the
current verbiage in the LCDS manual, it meets the definition of two scores; Code 3 (because
all bowel episodes were incontinent) and Code 1 (because the patient only had one bowel
movement).
Answer 1: The intent of H0400 - Bowel Continence is to gather information on the frequency of
bowel continence during the 3-day assessment period. Code 1-Occasionally incontinent should
only be selected if during the 3-day assessment period the patient was incontinent for bowel
movement once. This includes incontinence of any amount of stool at any time. Code 3-Always
incontinent is selected if during the 3-day assessment period the patient was incontinent for all
bowel movements (i.e., had no continent bowel movements).
If a patient has only one bowel movement that was incontinent during the 3-day assessment period,
and there were no episodes of continent bowel movements, then code 3-Always incontinent.
Added: September 2020
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 18 of 22Section K: Swallowing/Nutritional Status
K0200
Question 1: How should height be reported for item K0200A - Height for a patient with
bilateral lower extremity amputations? Should their current height or their height prior to
amputation be reported?
Answer 1: Item K0200A - Height records the most recent height of measurement for the patient.
Measure the patient’s height in accordance with the facility’s policies and procedures, which
should reflect current standards of practice (shoes off, etc.).
When reporting height for a patient with bilateral lower extremity amputations, measure and record
the patient’s current height (i.e., height after bilateral amputations).
Added: December 2020
Question 2: When entering a patient’s height and weight on admission for item K0200 do the
height and weight need to be measured while a patient is in the Long-Term Care Hospital?
Can they be estimated per facility policies and procedures or can they be reported based on
a height and weight obtained from documentation from another facility?
Answer 2: The intent of item K0200 - Height and Weight is to record the patient’s most recent
height since admission and record the patient’s weight based on the most recent measure in the
last 3 days. Only enter a height and weight that have been directly measured by your facility staff.
Do not enter a height or weight that is self-reported or derived from documentation from another
provider setting.
Added: March 2021
Question 3: If a patient’s height and/or weight was not measured within the 3-day admission
assessment period for K0200 is it okay to use a height and/or weight that was measured
day 5?
Answer 3: In order to be compliant, the admission assessment must be completed by the end of
the 3-day assessment period (i.e., midnight of the third calendar day). If a patient’s height and/or
weight cannot be measured during the 3-day assessment period enter a dash (–) to indicate “no
information” for K0200A - Height and/or K0200B - Weight. CMS expects dash use to be a rare
occurrence.
Added: June 2021
This document is intended to provide guidance on LCDS questions that were received by CMS help desks.
Responses contained in this document may be superseded by guidance published by CMS at a later date.
LCDS Quarterly Q&As, September 2021, Consolidated September 2020 to September 2021 Page 19 of 22You can also read
